Critical Control Points

CCP: Allergen Controls - Segregation & Labelling as CCPs

Allergen Controls as Critical Control Points

Quick answer

Allergens are chemical hazards that can cause severe, life-threatening reactions in sensitised individuals. Unlike microbiological hazards, there is no cooking or processing step that eliminates allergen risk. If an allergen is present in a food product, no amount of heating, cooling, or other treatment will remove it. This makes allergen control a strong candidate for CCP status in any food business that handles allergenic ingredients. UK law (the Food Information Regulations 2014, as amended by Natasha Law in October 2021) requires food businesses to declare the presence of 14 specified allergens. For non-prepacked food, this information must be available to customers at the point of sale.

Allergens cannot be removed by cooking or processing - segregation is the only control
UK law requires declaration of 14 specific allergens at point of sale
Allergen-free claims need dedicated equipment, storage, and preparation procedures

Key takeaways

Allergens cannot be removed by cooking or processing - segregation is the only control

UK law requires declaration of 14 specific allergens at point of sale

Allergen-free claims need dedicated equipment, storage, and preparation procedures

Allergen CCP failures are potentially life-threatening and require immediate corrective action

Update allergen information every time a recipe or ingredient changes

The UK 14 Allergens

UK food law specifies 14 allergens that must be declared: celery, cereals containing gluten (wheat, rye, barley, oats), crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts), peanuts, sesame, soybeans, and sulphur dioxide/sulphites (above 10mg/kg or 10mg/litre). Each of these must be identified in your hazard analysis and controlled through your HACCP plan. The list is specific - other allergens (such as kiwi fruit, which causes reactions in some people) are not legally required to be declared, though good practice may include them. For Natasha Law (PPDS - prepacked for direct sale), all 14 allergens must appear on a label on the packaging, with the allergenic ingredient emphasised (bold, underline, or contrasting colour).

Critical Control Points

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Allergen Segregation as a CCP

Segregation means keeping allergenic ingredients and allergen-free products apart throughout storage, preparation, and service. This is a CCP because there is no downstream step that eliminates the hazard. Critical limits for allergen segregation are procedural: "Allergen-free dishes prepared using dedicated equipment and surfaces," "Nut-free desserts stored on a separate shelf from nut-containing products," or "Gluten-free items prepared before gluten-containing items, with full clean-down between." Monitoring involves visual checks during preparation and storage audits. For each allergen-free claim you make, you need a documented control that prevents cross-contact. This might include dedicated utensils, separate storage areas, preparation sequence with validated cleaning between allergen groups, or separate fryers for gluten-free items. Record monitoring checks on a log, noting the time, area checked, and who conducted the check.

Allergen Information and Communication

Accurate allergen communication is both a legal requirement and a CCP control. For non-prepacked food (meals served in restaurants, takeaways, cafes), allergen information must be available to the customer at the point of sale. This can be through menu labelling, a separate allergen matrix, verbal communication from trained staff, or signposting (e.g. "Ask staff for allergen information"). The critical control is that the information given matches the actual ingredients used. This breaks down when: recipes change but allergen information is not updated, staff are not trained to communicate allergens, or substitute ingredients are used without checking allergen content. Your CCP monitoring should include verifying allergen information whenever recipes change, checking that staff can accurately state allergen content when asked, and auditing menus and allergen matrices against actual recipes at least monthly.

Corrective Actions for Allergen Failures

An allergen CCP failure is extremely serious. If an allergen-free dish has been contaminated with an allergen through cross-contact or incorrect ingredients, it must be discarded immediately and never served. If the food has already been served and the customer has an allergen, call emergency services (999) if there is any sign of anaphylaxis, administer adrenaline (EpiPen) if available and the customer requests it, and do not move the customer. After the immediate response: document everything, identify the root cause (wrong ingredient, cross-contact, communication failure), take corrective action (retrain staff, review procedures, change preparation method), and report the incident through your internal incident reporting system. All allergen near-misses should be treated as seriously as actual incidents - a near-miss means your control has already failed.

What to do next

Create an allergen matrix for your entire menu

List every dish against the 14 allergens. Update it whenever ingredients or recipes change. Display it where staff can reference it during service.

Designate allergen-free preparation equipment

Identify and label specific boards, utensils, and containers for allergen-free preparation. Consider a separate colour code (e.g. purple for allergen-free).

Run quarterly allergen awareness training

Test every team member on their ability to identify the 14 allergens, describe your segregation procedures, and respond to a customer allergen query.

Audit allergen labels monthly

Compare your allergen matrix and any PPDS labels against actual recipes and current supplier specifications. Ingredients change without notice.

Common mistakes to avoid

Mistake

Assuming cooking removes allergens

Instead

Heat does not destroy most food allergens. A nut allergen is just as dangerous in a cooked dish as in a raw ingredient.

Mistake

Relying solely on verbal allergen communication

Instead

Verbal information is prone to error, especially during busy service. Back it up with a written allergen matrix that staff can check.

Mistake

Using the same fryer for battered (gluten) and gluten-free items

Instead

Shared frying oil transfers allergens. Use a dedicated fryer for gluten-free items or do not make a gluten-free claim for fried products.

Frequently asked questions

Is allergen control always a CCP?

In most food businesses, yes. Because there is no processing step that eliminates allergen risk, the segregation and communication controls are the only barriers preventing harm to allergic customers. The HACCP decision tree typically identifies this as a CCP.

What is Natasha Law and how does it affect my HACCP plan?

Natasha Law (Food Information Amendment - England Regulations 2019, effective October 2021) requires food that is prepacked for direct sale (PPDS) to carry a full ingredients list with the 14 allergens emphasised. PPDS includes food packaged on the same premises from which it is sold, such as sandwiches made and wrapped in a cafe. Your HACCP plan must include labelling as a CCP if you produce PPDS food.

Can I use "may contain" labels to manage allergen risk?

Precautionary allergen labelling ("may contain traces of...") should only be used after a thorough risk assessment shows genuine cross-contact risk that cannot be eliminated. It should not be used as a blanket disclaimer. The FSA is working towards a standardised approach to precautionary labelling, and EHOs will challenge overuse.

What training do staff need for allergen management?

All food-handling staff need allergen awareness training covering: the 14 UK allergens, symptoms of allergic reaction, your specific control measures, how to respond to customer allergen queries, and what to do in an emergency. Training should be documented and refreshed at least annually.

Critical Control Points